EXHAUSTION OF ADMINISTRATIVE REMEDIES
STANDARD OF REVIEW = DE NOVO

Title VII specifically requires a federal employee to exhaust his administrative remedies as a precondition to filing suit. Brown v. General Servs. Admin., 425 U.S. 820, 832, 96 S.Ct. at 1961, 1965, 48 L.Ed.2d 402 (1976) ("Initially, the complainant must seek relief in the agency that has allegedly discriminated against him."); see also Cooper v. Bell, 628 F.2d 1208, 1211 (9th Cir. 1980) (Title VII "contemplates the invocation of administrative remedies as a condition precedent to litigation" by a federal employee) (citing Brown). Whether a claimant has satisfied that precondition is itself a question of law reviewable de novo.